Flashcards Studio

RuralTech, Inc., a VAT-registered taxpayer, is assessed PHP 7,250,000 by the BIR for deficiency in VAT for calendar year 2024. The BIR issues a collection order pending judgment on the assessment. RuralTech petitions for a temporary restraining order to prevent tax collection while the dispute is reviewed. The trial court denies the TRO. RuralTech pays the PHP 7,250,000 under protest and later files a separate action for refund and for a declaration that the assessment is invalid. (a) Identify the controlling doctrine governing whether an injunction may restrain tax collection. (b) Distinguish this doctrine from the ordinary rule on injunctions. (c) Apply the doctrine to RuralTech’s facts: should the injunction have been granted? what is the proper remedy, and what outcome can RuralTech expect in the refund action?